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Star Entertainment decision – Key takeaways for directors and officers

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Li-Jean Chew
Li-Jean Chew
Partner
Chuanchan (CC) Ma
Chuanchan (CC) Ma
Senior Associate
Marcella Cavallaro
Graduate

The Star Entertainment decision of the Federal Court provides important lessons for officers and non-executive directors. In particular, it re-iterates the importance of directors bringing an inquiring mind to their role, and engaging in active oversight of the organisation’s risk management and culture.

In the recent decision of Australian Securities and Investments Commission v Bekier (Liability Judgment) [2026] FCA 196, the Federal Court (Justice Lee) found that two former senior executives of The Star Entertainment Group Ltd (Star) breached their duty of care and diligence under section 180 of the Corporations Act 2001 (Cth) in relation to their handling of the risks associated with money laundering and criminal activity at one of Australia’s major casinos.

ASIC commenced proceedings in December 2022 against 11 current and former directors and officers of Star, each alleged to have contravened their statutory duty of care and diligence. The Court, which handed down its decision on 5 March 2026, ultimately found that only 2 defendants, Star’s former CEO & Managing Director, and General Counsel (who was also the Chief Legal and Risk Officer and the Company Secretary), had contravened their duty.

The claims against the non-executive directors were dismissed.[1] Nevertheless, there are key takeaways for non-executive directors from this decision. In his recent keynote address at the AICD Australian Governance Summit, ASIC Chair Joe Longo made it clear that nothing in the Star judgment changes ASIC’s appetite to hold corporate leaders to account for their governance failures, and promised that the regulator will continue to pursue cases where it can define the line of responsibility for directors.

The Court’s key findings in relation to:

CEO
  • The Court found that the CEO had contravened his duty of care and diligence on 4 separate occasions, by failing to inform the Board of key matters concerning the impermissible use of China Union Pay (CUP) cards, properly dealing with reports that identified deficiencies in Star’s processes for managing AML/CTF risks, and properly managing risks arising from the gambling junket.
  • The Court was satisfied that a reasonable director in the CEO’s position would have recognised that:
    • the deficiencies identified in a KPMG report increased the risk of Star failing to comply with its legal and regulatory obligations;
    • the other members of Star’s Board relied on him to bring to their attention any matters of which he was aware, that gave rise to a foreseeable risk that Star would breach its obligations or cause reputational harm; and
    • he should have obtained copies of Star’s communication with NAB concerning the usage of CUP cards in the casinos, upon receiving a warning letter from CUP. It would have been important to receive the communication trail in order to understand the precise terms of the representations Star had made in response to earlier requests for information.
General Counsel
  • The Court found that the General Counsel had contravened her duty of care and diligence on three separate occasions, by failing to inform the CEO and the Board of her knowledge of potential money laundering activities occurring within Star’s Sydney casino, the potential criminal links of junket organisations with whom Star dealt with, and misleading correspondence sent to NAB concerning the use of CUP cards.
  • The Court was satisfied that it was so obvious that she ought reasonably to have known that junkets presented serious risks to the integrity of the casinos, given the large sums of money involved and the potentially illicit sources of those funds. It was noted that she attended Board meetings, presented papers and received copies of reports, including the Horton Report which included “General Junket Risks”.
  • In addition, significant weight was placed on the fact that she was an experienced solicitor, and so with her legal education, training and experience, she was well equipped with the knowledge and skills to identify misleading representations, and to be attentive to the legal and commercial risks to which Star would be exposed if it dealt falsely with one of its key lenders.
Non-executive directors
  • The Court found that the non-executive directors had not contravened their duty of care and diligence considering the circumstances that they were entitled to rely on the information provided to them by senior management, and as a result, were misinformed about certain matters affecting Star. The Court recognised the inherent tension between management’s duty to inform and the Board’s duty to make inquiries, and the strength of the adverse findings against senior management meant that the Board were misinformed about matters affecting the company.
  • It was also accepted that, given the sheer volume of board materials, the non-executive directors were not in a position to identify relevant red flags in the information presented to them. They had not been provided with sufficient or appropriate information to enable them to further test management or to appreciate the full extent of the risks facing the company.

Key takeaways

Duty of care and diligence is applied rigorously, but in context

The Court reaffirmed that the duty of care and diligence is unchanged, but its application can be contextual. In companies that operate high-risk businesses or in heavily regulated industries (such as the Star which was exposed to significant AML/CTF risk), the expectations on directors’ oversight can be more exacting.

Directors need to acquire a clear understanding of the risks that their companies are exposed to, and determine where the most significant risks are which require greater attention.

Directors cannot just “set and forget” but need to actively monitor risks

Directors must actively monitor how the key risks of the organisation are being managed, and cannot treat them as mere compliance issues for management.

Indeed, the Board Charters of most companies will identify that a key responsibility of the Board includes setting the risk culture of the organisation, and monitoring the effectiveness of risk management within the organisation. As the Court noted, if Boards adopt these statements, it is presumed that they are supposed to be more than platitudes.[2]

The role of directors is not a passive one

While directors are entitled to rely on the judgment, information and advice of management, the role of directors is not a passive one. They are expected to actively engage, take a diligent and intelligent interest in the information available to them, understand that information, and apply an enquiring mind to their responsibilities.[3]

Passive acceptance of management assurances is not sufficient, particularly where there are red flags or any warning signs. Directors must have a willingness to interrogate, probe and, where necessary, challenge the information that is presented to them.[4]

Boards should control information flows

A key aspect of this case related to the adequacy of reporting lines and information flows.

In relation to the CEO, the Court noted that his responsibilities required him to act as a key conduit between the Board and executive management, and to take all reasonable steps to ensure that the Board was informed of key matters exposing Star to legal, financial or reputational risk.

However, this does not mean that management should increase the volume of information that is provided to directors. The risks of subjecting Boards to voluminous board packs were made clear by the Court in this decision – where a board pack contains multiple sections (such as summaries, followed by detailed papers, followed by appendices and attachments), while each section is defensible and in isolation apparently sensible, taken together, they are oppressive.[5]

Boards should give clear direction to management about their expectations in relation to the content and format of board papers, which should be both comprehensive and capable of digestion.[6] Management should aim to provide clarity and insight, rather than giving into temptation to include more as insurance against criticism.

As pointed out by Justice Lee (and emphasised by the ASIC Chair in his recent speech at the AICD Australian Governance Summit), directors cannot rely upon an inability to cope with the volume of information they receive as an excuse for not meeting directors’ duties.

AI is not a substitute for careful reading and interrogation

The Court raised that the usage of artificial intelligence (AI) by Australian boards is becoming more common to assist directors in discharging their duties, and by management in the creation of board packs. Whilst there is considerable potential for AI to assist in these situations, Justice Lee noted that AI should not be a substitute for careful reading and the interrogation of board materials.

The Court highlighted that all directors are required to take reasonable steps to place themselves in a position to guide and monitor the management of the company, and are expected to take a diligent and intelligent interest in the information available to them, understand that information, and apply an enquiring mind to their responsibilities. It is the responsibility of the directors to ensure that if they are to use AI, they do so in a responsible and appropriate manner, as ultimately, ethical reasoning and judgment rests with directors, not machines.[7]

1 Two other executives, the former Chief Casino Officer and the former CFO, settled their case earlier in 2025
2 Australian Securities and Investments Commission v Bekier (Liability Judgment) [2026] FCA 196 [1952].
3 Ibid [1945].
4 Ibid.
5 Ibid [384].
6 Ibid [393].
7 Ibid [394].

Liability limited by a scheme approved under Professional Standards Legislation.


© ADDISONS. No part of this document may in any form or by any means be reproduced, stored in a retrieval system or transmitted without prior written consent. This document is for general information only and cannot be relied upon as legal advice.

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